[F1614ZDTreatment of recipient of manufactured paymentU.K.
(1)Subsection (2) applies if a person has a manufactured payment relationship under which a manufactured payment is payable to the person.
(2)For the purposes of the charge to income tax on the person's income, the Income Tax Acts apply to the person as if the manufactured payment were a dividend or interest on the securities (as the case may require).
(3)Subsection (2) is subject to subsections (4) [F2and (5)].
(4)Subsection (2) does not apply in relation to the person so far as the manufactured payment is brought into account under Part 2 of ITTOIA 2005 in calculating the profits of a trade carried on by the person.
(5)Subsection (2) does not apply in relation to the person for the purposes of determining entitlement to double taxation relief in respect of any dividend or interest.
F3(6). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(7)For the purposes of this section “double taxation relief” means any relief given under or as a result of Part 2 of TIOPA 2010.]
Textual Amendments
F1Pt. 11ZA inserted (with effect in accordance with Sch. 29 para. 51 of the amending Act) by Finance Act 2013 (c. 29), Sch. 29 para. 1
F2Words in s. 614ZD(3) substituted (with effect in accordance with Sch. 1 para. 73 of the amending Act) by Finance Act 2016 (c. 24), Sch. 1 para. 63(9)(a)
F3S. 614ZD(6) omitted (with effect in accordance with Sch. 1 para. 73 of the amending Act) by virtue of Finance Act 2016 (c. 24), Sch. 1 para. 63(9)(b)